Public Water System (PWS) Engineering for Small Texas Water Systems
Am I a PWS?
Canyon Springs Engineering (CSE) works with small Public Water Systems (PWS). Our definition of "small" is serving water to a population of 25 to 5,000 persons.
This four word question is always the first question to address.
From the TCEQ web page titled: "Am I a Public Water System"?
If you supply water to other people, even if it's bottled, you might be a public water system (PWS). Find out if you are a PWS and, if so, what requirements you must meet.
Definition of a Public Water System
If you provide water to the public, you may be a public water system (PWS). State and federal regulations define PWSs [30 TAC §290.38(71), Fed Ref] A PWS provides potable water for the public’s use. A system must be a certain size to be considered public: it must have at least 15 service connections
OR
serve at least 25 individuals for at least 60 days out of the year. This includes folks that live in houses served by a system, but can also include people that don’t live there. For instance, people served could include employees, customers, or students.
PWS Exercise for Clients
When we are speaking with a potential PWS client, we like to walk them through the following exercise.
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Pick the 60 busiest days of the year.
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Are there 25 or more persons (employees, tenants, customers, visitors, students, etc.) at the location during each of those 60 days? (See Notes below.)
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If the answer is yes, you meet the definition of a PWS and should have a PWS approval to operate.
On the surface, this sounds like a straightforward and simple evaluation... and it is if one understands the various definitions.
Understandably, many small water system owners don't "speak the language" of PWS rules.
Contact Canyon Springs Engineering to help interpret the TCEQ PWS rules and how they might, or might not, apply to your specific scenario.
Notes:
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You must assume 100% occupancy + employees.
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Time on site is not a factor in this evaluation. A person there for 24 minutes is counted the same as a person there for 24 hrs.
- Visitors are typically included, though there are some scenarios where you can exclude them.
When you visit the TCEQ page linked above, do not get confused by the three types of public water systems. When evaluating the "Am I a PWS" question, you only look at the PWS definition. The definitions for the three types of systems can be confusing and often times, misinterpreted. If you meet the definition of a PWS, you will be categorized as one of the three types, whether you think they are applicable or not.
Bonus: This example came from TCEQ personnel:
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If you have an event venue and have 4,000 persons present every Saturday, that is only 52 days and are not a PWS. (52 less than 60 days)
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If you have 25 persons every Saturday and Sunday, that is 104 days with 25 persons and therefore would be a PWS. (104 greater than 60 days)
If you are a/an...
1
Business Owner
After reading “Am I a PWS” above and you think you might be a PWS, give us a call. We can help evaluate your specific scenario.
Examples:
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Residential Developments
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Campgrounds & RV Parks
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Tiny/Mini house campgrounds/compounds
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“Glamping” locations
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Mobile Home Parks
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Wedding/Event Venues
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Wineries with tasting rooms and some without
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Man camps
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Kids/Church Camps
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Churches
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Industrial/Commercial operations (with or without customers/visitors)
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Retail Shopping Centers
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Convenience Stores
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Office/Warehouse Facilities
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and Others
2
Engineer
Are you an engineer or architect that provides land development design and permitting services but not familiar with the ins and outs of PWS permitting?
As you may be aware, the TCEQ PWS approval process is very regimented and time consuming.
Give us a call. We would be happy to team/partner with you to provide full service to your client.
*Note, we can also conduct groundwater availability certification (GAC) studies.
3
Developer
You have property you want to develop and have questions about how you are going to provide potable water, or the County is asking for a groundwater availability certification (GAC) for platting.
Call us. We can help.
PSA: Please do this during your due diligence period. You do not want to find out water is not available to meet the needs of your project after it is to late.
4
Licensed Operator
Are you a TCEQ licensed water operator?
We know operators may know how to operate a system, but may not be as familiar with the compliance and paperwork parts.
If you have questions about TCEQ compliance, give us call.
*Note, we do not provide licensed operators as a service.
5
OSSF/Septic Sanitarian, Designer, Installer
This is not news to you, but Counties should ask about the water supply source when you apply for an OSSF permit.
If the project should need to be a PWS, we would appreciate it if you contact us or pass our contact info to your client.
If they ask about a WPAP or CZP, give us a call. We do not typically do those projects, but we can point you in the right direction.
6
Scared/Confused
Has the TCEQ, State/City/ County health official, or local groundwater conservation district contacted you about your water well or system (or lack of one)? Don’t be scared.
Agency officials are typically very nice and helpful, but… they do enforce the rules and they will not simply go away or forget about you. Don’t ignore them. Give us a call so we can help you get in compliance.
Depending on the situation, we might be able to determine that you should not be a PWS, thus removing any TCEQ involvement.
If you think you are not compliant with PWS rules and you have not been contacted by an agency (yet), give us a call and we can evaluate your system and make recommendations, if needed, to be compliant.
7
Water Well Driller
Last, and certainly not least, are water well drillers. In fact, a majority of my referrals come from drillers.
Water well drillers are often the first people to get called upon when someone only knows that they need a well or need someone to look at their well on a property they just bought.
A well driller will be quick to pick up on the fact that the proposed use will require PWS permitting.
Well drillers also know that a PWS well has additional requirements when compared to a "TDLR" well.
If you have questions about an existing or proposed well and if it needs to meet TCEQ PWS requirements, give us call.
If you read through all of the scenarios above, hopefully you have picked up on one theme… call CSE with your PWS questions.
If you have made this far, we highly recommend you review the FAQ page for more information.
Also check out the Box Score page to get an idea of submittal types and review times.
Need help on a water or wastewater project?
The team at CSE is here to assist you. Contact us by phone, email or contact form.